ML19339D858

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Response to Formal Disagreement with Adversary Characteristics, Attributes, or Tactics Employed or Prepared as Part of an NRC-Evaluated FOF Exercise - Disputed Item 053000315, 316/2019-01 and 05000315, 316/2019-02
ML19339D858
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/05/2019
From: Clark J
Security Performance Evaluation Branch
To: Scarpello M
Indiana Michigan Power Co
Clark J
References
IR 2019001, IR 2019002
Download: ML19339D858 (3)


See also: IR 05000315/2019002

Text

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION

December 5, 2019

Mr. Michael Scarpello, Director

Nuclear Regulatory Affairs

Indiana Michigan Power Company

Nuclear Generation Group

One Cook Place

Bridgman, MI 49106

SUBJECT:

RESPONSE TO FORMAL DISAGREEMENT WITH ADVERSARY

CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED OR

PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE

EXERCISE - DISPUTED ITEM 05000315,316/2019-01 AND

05000315,316/2019-02

Dear Mr. Scarpello:

Thank you for your letter dated November 26, 2019, to the Division of Security Operations

(DSO), Security Performance Evaluation Branch (SPEB) titled Formal Disagreement with

Adversary Characteristics, Attributes, or Tactics Employed or Prepared as Part of an

NRC-Evaluated Force-on-Force Exercise, in accordance with Addendum 4 of the U.S. Nuclear

Regulatory Commission (NRC) Inspection Procedure 71130.03 Contingency Response -

Force-on-Force Testing.

In your letter you disputed a tactic, technique, or procedure (TTP) within Scenario 1 and

Scenario 2 developed by an NRC Force-on-Force inspection team.

The NRC has carefully reviewed your formal escalation and concluded that the disputed TTPs

are approved for use within the NRC-evaluated exercise scenarios for the following reasons:

(1) it is within the design basis threat; (2) supported by available data; (3) within your program

requirements to provide defense-in-depth; (4) can be safely performed and controlled; and

(5) provides a credible and realistic challenge to your sites protective strategy.

The Enclosure transmitted herewith contains Safeguards Information. When

separated from the enclosure, this transmittal document is decontrolled.

SAFEGUARDS INFORMATION

M. Scarpello

2

SAFEGUARDS INFORMATION

If you would like to appeal this decision, provide a written response within 3 days from the date

of this letter with the basis of your appeal to the Director, DSO.

Sincerely,

/RA/

Jefferson Clark, Acting Branch Chief

Security Performance and Evaluation Branch

Division of Security Operations

Office of Nuclear Security and Incident Response

Non-public Enclosures:

1. NRC Response to Disputed Item

05000315,316/2019201-01

2. NRC Response to Disputed Item

05000315,316/2019201-02

SAFEGUARDS INFORMATION

M. Scarpello

2

SAFEGUARDS INFORMATION

SUBJECT:

RESPONSE TO FORMAL DISAGREEMENT WITH ADVERSARY

CHARACTERISTICS, ATTRIBUTES, OR TACTICS EMPLOYED OR

PREPARED AS PART OF AN NRC-EVALUATED FORCE-ON-FORCE

EXERCISE - DISPUTED ITEM 05000315,316/2019-01 AND

05000315,316/2019-02

DATE:

December 5, 2019

DISTRIBUTION:

J. Clark, NSIR

ADAMS Access No. ML19339D858

OFFICE

NSIR/DSO/SPEB

NSIR/DSO/SPEB

NAME

J. Berry

J. Clark

DATE

12/2/19

12/5/19

OFFICIAL RECORD COPY